Latest Compliance - Cosigner Topics

Would you explain, please, the difference (if any) in treating income and debts jointly or separately for co-signers vs. for joint applicants?

Credit Reporting on Bankrupt Accounts

We are dealing with the problem of credit reporting on bankrupt accounts. Our reporting is done at the loan level therefore non bankrupt co-borrowers are affected. Can we just suppress reporting?

Joint Intent Required at Application?

Is joint intent required at application or at a completed application status? The question arose, because if joint intent is not established at application, can any change prior to a completed application status be considered contemporaneous?

Disclosures for Co-Signer on Consumer Purpose

On a consumer purpose loan secured by the borrowers' home, is it required to give a co-signer (not an owner of the home) the Servicing Disclosure, and the Credit Score Disclosure?

Reg AA - Co-signer vs Co-maker

Reg AA, Sec. 227.12 Definitions defines a cosigner. Is a co-maker defined the same way?

Reg B - Joint Credit & Cosigners

Is a Reg B Notice of Intent to Apply for Joint Credit needed when a Cosigner is used?

Consumer Loan and Cosigner Procedures

When a consumer loan has a cosigner, does the cosigner have to supply an application and do we need to run a credit report? What other documents are required from the cosigner?

Adverse Action Notice to Multiple Borrowers

Question: When a loan has two borrowers who live at different addresses does the bank need to provide the negative information notice to both individuals, or is one sufficient?

Definition of Co-signer and Co-borrower

What are the separate definitions of a co-signer and a co-borrower?

Needed: One Crystal Ball

There is almost no area of banking where the future and present responsibilities change as often and as drastically as the front line.

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Most Popular Compliance Content

Discontinuing cash advance service

Can a bank offering VISA cash advances stop offering cash advance services?

Does one mistake make a business an MSB?

We have a commercial customer that cashes checks, but they are not registered as an MSB because they have a policy to not cash checks for one person over $1000 in one day. We found one instance of checks cashed over $1,000 for one person. Are we required to have the customer register as an MSB, or can we verify their check cashing policy and continue to monitor the account for any further instances?

Lost Debit Card

We have a customer that lost their debit card but didn't notify us until day five. Under Visa's zero liability policy, would this be considered "gross negligence"? The charges do not all add up to $500.00, so are we required to give the customer any credit at all?

Consumer Protection for mistake in loan payment transaction

Scenario: A bank employee inadvertently makes an error while processing a payment authorized by phone by the customer, for example, customer authorized his/her personal loan monthly payment of $100 but the employee processes a debit for $101, or $96. Could this be considered an unauthorized electronic fund based on the amount error? Can this be considered a violation of other consumer protection law/reg? UDAAP?

Records retention and canceled remittance transfer

Regarding a cancellation request of a consumer foreign remittance transfer - are there any document retention requirements related to the canceled wire transfer request? Is the FI required to retain a copy of the wire transfer request form or any other documentation related to the transaction since it never occurred if canceled within the 30-minute window? Our bank has a log to record all canceled international wire transfer requests, but that is the only documentation.

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